Pet Food Processing: Shifting from Reactive to Proactive

That shift in focus—from response to prevention—has drastically changed how food manufacturers construct their facilities; how the materials are sourced; how packaging is approached—and much more. And, since FDA regulates pet food manufacturing as well as human food and beverages, there is much crossover between pet food and human food manufacturing when it comes to safety and compliance with FSMA. In short, pet food production is more than ever closely aligned to its human counterpart. The law also provides FDA with the authority to conduct facility inspections to verify FSMA compliance and to ensure imported foods meets U.S. food safety standards.

In the first of this four-part series, we looked at the general importance of food safety for people and pets; in this next installment, we talk about how pet food regulation (as well as their human counterparts’ food and beverages) has shifted from a reactive to a much more proactive approach.

Pet Food Regulation

Previous to the FSMA, there was a CFR standard that petfood canneries were held to, but the pet food industry itself was largely self-governed. As a result, some smaller companies took advantage of the lack of federal (and even state) oversight and reaped profits at the expense of food safety.

Then came the 2007 melamine recall scandal that caused renal failure in pets and resulted in widespread panic and extensive recalls of pet food. This incident exposed the void in federal regulations for the food safety of pet and animal feed.

The FSMA Preventive Controls for Animal Feed rule means that, as stated above, requirements for animal food manufacturing are now held to the same standard as those of human food production. With this new prevention-based system, the FDA expects to see reductions in the risk of serious illness and death to animals as hazards are controlled.

Animal Food Key Requirements in FSMA

The key requirements, as pointed out by the FDA, for the new legislation are:

• Current Good Manufacturing Practices (cGMPs) are established for animal food production.
• Covered facilities must establish and implement a food safety system that includes an analysis of hazards and risk-based preventive controls. The rule sets requirements for a written food safety plan that includes Hazard Analysis, Preventive Controls, and Oversight and Management of preventive controls (Monitoring, Verification, Recall Plan). This is no different from the Hazard Analysis and Risk-Based Preventive Controls (HARPC) requirements that impact human food manufacturers. [HARPC is part of FMSA.]
• Supply-chain program is more flexible, with separate compliance dates established.
• The definition of a “farm” is clarified in the Preventive Controls for Human Food final rule to cover two types of farm operations. Operations meeting the definition of “farm” are not subject to the preventive controls rule. The two types of farms are Primary Production Farms and Secondary Activities Farms.
• Feed mills associated with farms (vertically integrated operations) are not covered.

With few exceptions, just as with human food, FSMA also requires pet food makers to identify and evaluate hazards (biological, chemical or physical) that may be associated with the foods they make and put into place procedures (“preventive controls”) that address those hazards; develop and implement a food safety plan detailing the steps they are taking to ensure product safety, from the sourcing ingredients to carrying out a product recall if ever needed; and comply with FSMA requirements regarding foreign suppliers and sanitary transportation for both finished pet food/treats and ingredients.

Full summaries of each requirement can be found on the FDA’s page about preventive controls for food for animals.

Pet Food Regulation in Practice

In the U.S., pet food is among the most highly regulated of all food products and must meet federal and state requirements. Nearly all states also require products sold to be registered, and their labels must adhere to strict requirements regarding product names and ingredients. Most states regulate pet food products under their animal feed laws. State regulators also regularly inspect pet food manufacturing facilities to verify that state cGMPs are being followed, appropriate documentation is in place, and a food safety plan is written and followed.

An ingredient cannot be used in pet food until it has been accepted by FDA and adopted by the Association of American Feed Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for pet food that states can adopt into their respective state laws and regulations.

In Summary…and More to Come

Once again, the focus of 2011’s FSMA for human and animal food is prevention of illness, rather than reacting and correcting issues that arise. In part one of this series, we went over some of the background and key points of the Act. This article delves deeper into the regulations specific to pet food manufacturing, and the requirements pet food producers must be ready to meet. In the next installment of this series, we take a dive into FSMA’s guidelines for Sanitation Details, Traffic Flow, Pressurization, and Hygienic Mapping. We’ll also discuss overcoming the fear of salmonella contamination, including a look through Gray’s unique Window into the Kitchen (WINK) System.